In the Matter of the Claim of Wendy Wagner
Wendy Wagner sustained work-related injuries in 1977, eventually classified with a permanent total disability. After denials of medication requests in 2022-2023, she sought a medical exemption from the Medical Treatment Guidelines and Drug Formulary. A Workers' Compensation Law Judge (WCLJ) denied her request, stating a 33-year-old agreement for treatment by a non-coded physician was outside Board jurisdiction. The Workers' Compensation Board affirmed this decision, finding no authority to compel the carrier to pay for non-coded medical providers and that other issues were not ripe. Wagner's subsequent application for reconsideration and/or full Board review was denied. The Appellate Division affirmed the denial of reconsideration, limiting its inquiry to whether the Board's denial was arbitrary and capricious or an abuse of discretion, finding no such abuse. The court also noted that many issues raised were not properly presented to the Board initially.